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consultation response

  • To: comments-closed-generic-05feb13@xxxxxxxxx
  • Subject: consultation response
  • From: KJ Mobberley <kjmobberley@xxxxxxxxx>
  • Date: Thu, 7 Mar 2013 17:43:04 +0000

Hi, I'm responding to your call for consultation:

*ICANN is seeking public comment on the subject of "closed generic"
> applications and whether specific requirements should be adopted
> corresponding to this type of application. Stakeholder views are invited to
> help define and consider this issue*

I've been building web sites since 1999. My professional work currently
focusses on freelance consultation and agency work building and growing
sites fro small businesses and organisations across public, private and
third sectors. I also have a background in community arts, environmental
conservation and social research.

I feel the adoption of closed generic top level domains cannot help but be
damaging, to the global public interest as well as to co-operation and
competition between commercial concerns.

* comments would be helpful in regard to proposed objective criteria for:**
> classifying certain applications as "closed generic" TLDs, i.e., how to
> determine whether a string is generic
> *

Let us work through an example. Suppose '.insurance' was registered by one
cartel or company as a 'closed generic' TLD. Not only would this grossly
unfair to competitors within the insurance field, but consider that the
insurance industry is a matter of great public interest in itself. In this
case, since taking out insurance is often a legal requirement for many
public activities, consumers deserve impartial and independent data and
advice, and the ability to network on a 'peer to peer' basis, around the
generic issue 'insurance'.

Suppose if, as a public service, I wished to create a site independent of
any commercial insurance provider precisely to answer such a need -  site
or web app designed to enable members of the public to share advice on
getting the best out of the insurance industry as a whole. If there were a
TLD '.insurance' I would consider it natural and normal to want to register
my sites' domain under that TLD  - impossible if it was closed.

To take another example from MicroSoft's submission to you, the pursued
closed generic TLD '. book' - is it really necessary to have a consultation
to find out why this is such a bad idea? To exclusively own such a TLD
would surely be tantamount to controlling a large element of the public and
private perception of what a book is and what the word means.  And of
course the same applies to any generic term. A kind of privatised

I fail to understand why this would be necessary. It does seem rather
obvious that the concept of closed generic TLDs would only serve
protectionist industrial cartels, without any obvious side benefit for the
general marketplace of ideas, the market of goods and services, or to the
world in general.

*determining the circumstances under which a particular operator should be
> permitted to adopt "open" or "closed" registration policies.*

To be honest I think the problem you've got is that 'generic closed' is of
course a total contradiction in terms. I cannot see any circumstances in
which it would improve the network we have. It seems to me the introduction
of this concept would only add to the current, creeping sense of doom
associated with the enclosure of the commons, the increasing sense that the
Internet as we have known it is in grave danger. Danger of abolition by
stealth, to be replaced with a network which adds nothing to our way of
life, rather simply mirroring existing power dynamics in the global games
those in positions of high power like to play. Danger of being 'tamed'.

My feeling is that this proposal will only cause resentment amongst
developers and users, and be a significant step towards a 'closed'
internet, a two-tier internet in which any sense of a level playing field
has been eradicated.

I'm sorry but that's not the Internet I signed up to contribute to.

I do not accept any argument that some closed generic TLDs may foster a
sense of trust that the content hosted on such a domain is 'authoritative'.
To my mind such authority is earned by the quality of the content itself,
and the tests of word of mouth and experience. Authority or trust surely
cannot be assumed on the basis of the ownership of an exclusive internet

In conclusion I would simply ask you to consider frankly and without
illusion whose interests would be served by closed generic TLDs, and then
ask whether it is the purpose of ICANN to serve those interests.

I would urge you to reject the policy of 'closed' TLDs, and require any new
TLDs to be 'open'.

Thank you for listening, and here's hoping you do the right thing.

regards, KJ Mobberley.

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